United States
            Environmental Protection
            Agency
                Office of
                Inspector General (2441)
                Washington DC 20460
EPA-350-K-01-002
 November 2001
  \
Office of Inspector General
Semiannual Report
to the Congress
           April 1,2001 through
           September 30, 2001
EPA personnel set up an air monitoring station near
"ground zero" of the World Trade Center (EPA photo)
                           EPA investigators and other law enforcement officials
                           search through World Trade Center debris taken to a
                           Staten Island landfill (EPA photo)

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We are agents of positive change striving for continuous improvement in our Agency's
management and program operations, and in our own offices.
The Inspector General Act of 1978, as amended, requires the Inspector General to:
(1) conduct and supervise audits and investigations relating to programs and operations
of the Agency; (2) provide leadership and coordination, and make recommendations
designed to (a) promote economy, efficiency, and effectiveness, and (b) prevent and
detect fraud and abuse in Agency programs and operations; and (3) fully and currently
inform the Administrator and the Congress about problems and deficiencies identified
by the Office of Inspector General relating to the administration of Agency programs
and operations.
          1.   Contribute to improved environmental quality and human health.

          2.   Improve EPA's management and program operations.

          3.   Produce timely, quality, and cost-effective products and services that
              meet customer needs.

          4.   Enhance diversity, innovation, teamwork, and competencies.

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                      The report summaries included in this semiannual report clearly illustrate
                      some of the challenges the new Administration faces in its quest to
  ^^^       ^.        deliver efficient and effective environmental programs.  During this
• %!l!*C;?f  •   *   semiannual reporting period,  the Office of Inspector General identified several
^f ¥t'%>^ J%  opportunities for improved environmental quality, greater accountability, and
m'"',',~. :""^^:"  better use of limited resources.

  ",g||^  "'',.'  An OIG review showed that most states use only their own data when
^f^'r/'^-^,.^  assembling and evaluating data, developing monitoring approaches, and
•lr^- -••'•'•" 'JP'^  adopting water quality standards. The lack of collaboration among states
   f*;;  ;:^: ^      results in inconsistent listings of impaired waterbodies that cross or serve as
   —'Iji^;.       state boundaries.  For example, Tennessee and Arkansas had inconsistent
;,,^ |K:'; ?; %,„  j  listings for the Mississippi River. Tennessee conducted fish tissue monitoring,
.'    benefits, and others would have been  performed regardless of the
V;*^^-  -t;   T:%  enforcement action. One project was  completed years before the violation
•  ':j',*^:'.'.'\   •  x*  was even identified.

|  ':           ^  We documented continuing problems with EPA holding grantees accountable.
• H            '  ln reports dating back to 1998, the National Asian Pacific Center on Aging
t^jl^iW^-,'-^  (NAPCA), which administers certain EPA cooperative agreements, was cited
ft^*%;.    *  '  for problems with cash management.  A March 2001 OIG report advised  EPA
f. J^-^-^V'    of a $1 -8 million embezzlement by an NAPCA employee, and a September
^t,- '•'   -B*-?'  '  2001 OIG report indicated a continuation of NAPCA's inability to properly
j:^,."^/^'     t  manage EPA awards.  A 1999 OIG report disclosed that EPA allowed the
^j^jj^.. "••'', J'  National Association of Minority Contractors (NAMC), which received a grant
                                                        U.S. Environmental Protection Agency
                                                        Region 5, Library (PL-12J)
                                                        77 West Jackson Boufevard, 12th Fk»
                                                        C*»cago. JL  60604-3590

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of $750,000, to draw down all of the funds even though NAMC completed only
a small portion of the required work. The original grant was for $500,000 with
a project completion date of March 1997.  EPA awarded NAMC a $250,000
increase in March 1997 and extended the project completion date to June
1998. Despite the additional funds and time extension, a large portion of the
work still has not been completed.

In response to an allegation, the OIG determined that EPA unnecessarily
provided $1.238 million to the State of Michigan from the Superfund Trust
Fund to defray the cost of replacing the Ingalls Avenue Municipal Well at the
Petoskey Municipal Well Field Superfund Site with a new drinking water
source.  The City of Petoskey, a resort community on Lake Michigan, owns
the Well and needed to replace its water supply to meet federal and state
drinking water standards. We found that no Superfund remedy was needed
since pollutant levels were within the federal standard and future risk to the
well was unlikely.  This action by Region 5 could set an inappropriate
precedent for other parties to seek Superfund monies to address non-
Superfund issues. In addition, these funds could have  been used to clean
more seriously contaminated sites. Region 5 stated that it acted in
accordance with applicable laws and regulations despite cautionary warnings
from EPA 's  Office of General Counsel. Records indicated that congressional
representatives and the Governor of Michigan requested that EPA use
Superfund monies for an alternate water supply.

Each federal agency was required by Presidential Decision Directive 63 (PDD
63) to review the critical physical infrastructures needed to  perform its mission.
Our review of EPA's implementation of PDD 63 indicated that EPA had not
addressed certain aspects of planning necessary to protect critical
infrastructures.  Consequently, PDD 63 requirements such as conducting
vulnerability  assessments and risk mitigation, and implementing  a Vulnerability
Awareness and  Education Program had yet to be achieved. In addition,
funding problems delayed attempts by EPA and the private sector to establish
a national framework for protecting the physical infrastructure of the nation's
water supply systems in emergency situations as required by PDD 63.

The OIG remains steadfast in its resolve to assist the Agency with the many
challenges, current and future, associated with environmental protection. I
look forward to working collaboratively with the new Administration and EPA to
ensure timely resolution of complex problems and an emphasis on achieving
environmental results.
                                                L.
                                        Nikki L. Tinsley          U
                                        Inspector General


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                    Profile  of Activities and Results
                            April 1, 2001 to September 30, 2001
            OIG-Managed Reviews
   (Reviews Performed by EPA, Independent Public
          Accountants, and State Auditors)
                                 Other Reviews
                     (Reviews Performed by Another Federal Agency
                             or Single Audit Act Auditors)
Questioned Costs'
  - Total
  - Federal
                        April 1, 2001 through
                        September 30, 2001
$6.2
$3.8
Recommended Efficiencies *
  -Federal                         $31.9

Costs Disallowed to be Recovered
  - Federal                         $39.3

Costs Disallowed as Cost Efficiency
  - Federal                            $0

Reports Issued - OIG-Managed
Reviews                              34
  - EPA Reviews Performed by OIG
  - EPA Reviews Performed by            0
    Independent Public Accountants
  - EPA Reviews Performed by          __0
    State Auditors                      34
  Total

Reports Resolved
  (Agreement by Agency officials to        70
take satisfactory corrective actions) ***
       Fiscal
        2001
$31.4
$27.7
       $32.1


       $54.4


         $0


         60

          0

         _0
         60



         172
                                    April 1, 2001 through
                                    September 30, 2001
Questioned Costs *
  - Total
  - Federal

Recommended Efficiencies *
  - Federal

Costs Disallowed to be Recovered
  - Federal

Costs Disallowed as Cost Efficiency
  - Federal

Reports Issued - Other Reviews
  - EPA Reviews Performed by
    Another Federal Agency
  - Single Audit Act Reviews
  Total

Agency Recoveries -
  Recoveries from Audit Resolutions
  of Current and Prior Periods
  (cash collections or offsets to
  future payments) **
                     Fines and Recoveries
                     (including civil) ****
                     Investigations Opened
                     Investigations Closed

                     Indictments of Persons or Firms
                     Convictions of Persons or Firms
                     Administrative Actions Against
                     EPA Employees / Firms

                     Civil Filings/Settlements
                   April 1, 2001 through
                   September 30, 2001


                          $3.1 M

                             29

                             29

                             10

                             11
                             30

                              2
                                Fiscal
                                2001


                                $5.2M

                                  42

                                  54

                                  24

                                  27


                                  44

                                   3
$1.3
$1.3
                                                 $0


                                                $1.9


                                                 $0
                                                 81
                                                124
                                                205
                                              Fiscal
                                              2001
$3.7
$3.7
         $0


        $5.1


         $0
        214
        211
        425
                                               $2.5

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Table of Contents
 i », >v -•*':••• JS  Goal 1: Contribute to Improved Environmental Quality and
           ".  Human Health   	
              Goal 2: Improve EPA's Management and Program Operations

              Goal 3: Produce Timely, Quality and Cost-Effective Products
              and Services That Meet Customer Needs 	
10
17
              Goal 4: Enhance Diversity, Innovation, Teamwork and Competencies  ....  21

             Audit Report Resolution and Summary of Investigative Results
              Status Report on Perpetual Inventory of Reports in Resolution Process    	24
              Status of Management Decisions on Inspector General Reports  	25
              Inspector General Issued Reports With Questioned Costs  	25
              Inspector General Issued Reports With Recommendations that Funds Be
               Put to Better Use	26
              Summary of Investigative Results	27

             Appendices
              Appendix 1- Reports Issued  	28
              Appendix 2- Reports Issued Without Management Decisions (Available upon request)
             Correction: The May 2001 EPA Office of Inspector General Semiannual Report to the
             Congress contains an error in the title of the second article on page 17. The title, " Former
             State Air Authority Director and Employee Sentenced " is incorrect and should be " Former
             Air Authority Director and Employee Sentenced". The individual referred to as a "state air
             authority director " was not a state employee. We sincerely regret this error.
                     Printed with vegetable oil based inks on 100% recycled paper (minimum 50% postconsumer)

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Goal 1: Contribute to Improved Environmental Quality and Human Health
                        The work of the OIG is designed to assist EPA in achieving its
                        environmental goals, thus contributing to environmental
                        improvements. The following represent some examples of the
                        more significant efforts under this OIG goal.
States
Inconsistently List
Impaired Water
Bodies Which May
Delay TMDL
Implementation
States inconsistently list impaired water bodies that cross or serve as state
boundaries. This occurs because the States do not collaborate with each other when
assembling and evaluating data, developing monitoring approaches, and adopting
water quality standards. There are many differences in how states assemble and
evaluate monitoring data, and most states only use their own data and do not
consider or use data from other states. The lack of collaboration may delay
development and implementation of Total Maximum Daily Load (TMDL) limits
and the timely cleanup of polluted waters. Increased TMDL costs may also occur.

For example, in 1998, Arkansas and Tennessee had inconsistent listings for the
Mississippi River, which serves as a boundary between the two states. Tennessee
had conducted fish tissue monitoring, listed the river as impaired, and imposed a
commercial fishing ban in the Memphis area. Arkansas, on the other hand, had not
monitored the Mississippi River for several years, did not consider the river
impaired, and allowed commercial fishing off the Arkansas banks of the river.

EPA is generally not working with states  on addressing the inconsistent listings
under section 303(d) of the Clean Water Act for impaired water bodies that cross or
serve as state boundaries.  EPA does not have a system to review states' 303(d) lists
for consistency, and does not facilitate data sharing.

We recommended that the EPA Office of Water encourage collaboration among
states in developing similar methods to assemble and evaluate data, monitor, and
adopt water quality standards for shared water bodies. We also recommended that
EPA better define the data to be used and evaluated in developing a state's 303(d)
list, and improve or develop a national database to facilitate data sharing among
states. In addition, we recommended that  EPA modify regional offices' existing
303(d) list review processes to include checking for inconsistent listings of shared
water bodies, and coordinate the sharing of water quality monitoring data in a
format accessible to all  potential users.

The Office of Water generally agreed with the findings and recommendations, and
identified a number of actions it plans to take in response. We issued our final
report (2001-P-01225) on September 27, 2001. A response to the report is due on
December 26, 2001.
                                                          PAGE 1-APRIL 1,2001 THROUGH SEPTEMBER 30,2001

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 Region 6 SEPs
 Benefitted
 Violators More
 than the
 Environment or
 Public Health
Region 6 did not effectively implement the Supplemental Environmental Project
(SEP) program in a manner that primarily benefitted the environment and public
health. SEPs are projects in which a violator agrees to provide substantial
environmental or public health benefits in exchange for a reduction in penalties.
However, in the majority of cases reviewed, violators potentially profited from their
SEPs.

For 6 of 10 SEPs reviewed, the total estimated cost savings or revenue gains to the
violator over the useful life of the projects ranged from $572,640 to more than $32
million. In some cases, projects did not provide significant environmental or public
health benefits.  In addition, requirements in SEP settlement agreements, monitoring
of violator compliance with SEP requirements, and documentation of SEP
eligibility determinations were not sufficient to ensure SEPs were properly
completed and consistent with SEP priorities and goals. Also, Region 6 SEPs data
entered into EPA's Enforcement Docket System was not always correct or
consistent, preventing adequate measurement  of EPA progress.

We recommended that Region 6 establish a more effective process for evaluating
SEP quality'. This would include obtaining information on and evaluating potential
economic benefits for the violator; determining whether proposed SEPs would have
been performed in the normal course of business regardless of EPA action; and
assessing the environmental or public health benefits from such projects. In
addition,  Region 6 needed to strengthen its data entry controls, and properly train
staff regarding SEP. We also recommended that the EPA Office of Enforcement
and Compliance Assurance clarity' its SEP guidance, and revise the Docket Data
Dictionary to more specifically indicate required SEP entries.

In responding to our draft report, EPA welcomed our recommendations for
improving the Agency's implementation of the SEP policy. The  Agency's response
indicated that many corrective actions had been initiated, including: management
review and approval of all SEPs; additional EPA-wide SEP guidance: a SEP
seminar; additional  training; and development of SEP checklists and certifications.
We issued our final report (2001-P-00014) on August 22, 2001. A response to the
final report is due November 22, 2001.
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State Enforcement
of Water
Discharge
Programs Could
Be More Effective
State enforcement programs could be more effective in deterring noncompliance
with water discharge permits and. ultimately, improving the quality of the nation's
water.  EPA and the states have been successful in reducing point source pollution
since the Clean Water Act passed in 1972. However, despite this tremendous
progress, nearly 40 percent of the nation's assessed waters are not meeting the
standards states have set for them.

The state enforcement strategies we evaluated need to be modified to better address
environmental risks, including contaminated runoff.  EPA's core program and
monitoring systems have emphasized major industrial facilities and larger sewage
treatment plants, and have not sufficiently considered other sources. State strategies
were also inhibited by:

    •   Inadequate water quality data.
    •   Incomplete permit data.
    •   Insufficient EPA-state relationships.
    •   State concerns over regulating small and economically vital businesses and
       industries.
                          Wastewater discharge from a California facility into Suisun Bay (photo by Dan Cox , EPA
                          OFG)

                          States evaluated did not have sufficient information on dischargers to effectively
                          implement their enforcement programs. One reason was that EPA's Permit
                          Compliance System was incomplete, inaccurate, and obsolete, since the growth,
                          variety, and complexity of the regulated community had greatly outstripped the
                          system capabilities. States had other weaknesses in their compliance monitoring
                          and enforcement systems, including not reporting serious, significant violations.
                                                            PAGE 3-APRIL 1,200 [THROUGH SEPTEMBER 30,2001

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                           Moreover, states needed to improve their enforcement response to significant
                           violations. Although EPA's goal was full compliance, only 10 states reported a
                           compliance rate of 90 percent or better during fiscal 2000, while 20 states reported
                           less than 75 percent compliance.
                                       State Enforcement Program Deficiencies
                                Compliance systems lacked data for hundreds of thousands of smaller
                                dischargers
                                Serious toxicity violations and other violations were not reported
                                Strategies for identifying unpermitted storm water dischargers were incomplete
                                Enforcement actions were issued a year or more after violation
                                Penalties failed to recover economic benefit of noncompliance
                                Proactive strategies to avoid serious violations needed further development
                           We recommended that EPA collaborate with states to develop risk-based
                           enforcement priorities, make modernizing its Permit Compliance System a high
                           priority, better define significant violations, and routinely determine whether states
                           are fulfilling their obligations to monitor and enforce discharge programs.

                           EPA's Office  of Enforcement and Compliance Assurance agreed with several of the
                           conclusions and recommendations in our report. However, the Office expressed
                           concern about the way some of the issues, as well as EPA's role, were
                           characterized. We issued our final report (2001-P-00013) on August 14, 2001.  The
                           Agency's response is due November 13, 2001.
 Although EPA
 Actions at
 Tranguch
 Gasoline Site were
 Sufficient,
 Communication
 Needs
 Improvement
We determined that the remediation efforts taken by EPA at the Tranguch Gasoline
Site, in Hazleton, Pennsylvania, appeared sufficient to ensure the safety of area
residents, although EPA could have communicated better with those residents.

We conducted this review as a result of a hotline complaint alleging that Region 3
mismanaged the Tranguch site, where vapors from a gasoline spill stemming from
corroded underground storage tanks caused a major concern for area residents. We
found that EPA took timely and effective actions to address hazards in residents'
homes.  In particular, we noted that:

        •   Homes sampled were representative of the spill area.
        •   EPA's decisions on taking remediation were sufficient.
        •   A  buyout of residents' homes was not warranted.
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  Tranguch Gasoline Site in Hazleton, Pennsylvania

 However, we found that EPA should have communicated better with residents and
 the Pennsylvania Department of Health. EPA's poor communication resulted in
 many residents not trusting EPA, and EPA may have overcompensated by taking
 extra actions that may not have been needed. These actions may result in as much
 as $2.8 million in unnecessary costs.

 We recommended that the Region 3 Administrator, to ensure better communication
 with the public at future sites, provide additional training to appropriate EPA
 personnel on risk communication, and develop a risk communication reference
 guide.  Region 3 concurred with our recommendations. We issued the final report
 (2001 -P-00015) on August 29, 2001. A response to the final report is due
 November 27, 2001.
Superfund Monies
Used
Inappropriately at
Petoskey
Superfund Site
EPA Region 5 did not select the appropriate remedy in its Interim Record of
Decision to provide $1.238 million to Michigan from the Superfund Trust Fund for
the cost to install an air stripper for the Petoskey Municipal Well Field Superfund
Site. The money was used instead to help defray the cost of a new drinking water
source, which could set an inappropriate precedent for other parties to seek
Superfund monies to address non-Superfund issues, such as local drinking water
problems.

OIG had received an allegation claiming that Region 5's selected remedy was
potentially a waste  of Superfund monies because an EPA response was not
warranted and the process for determining the cost of the air stripper was improper.
We concluded that  although the remedy was unnecessary from a Superfund
perspective.  Region 5 approved and contributed $1.238 million from the Superfund
Trust Fund (the capital cost of the air stripper) to partially defray the City's cost of
replacing the Well.  Specifically:
                                   PAGE 5-APRIL 1.2001 THROUGH SEPTEMBER 30,2001

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                            • The air stripper remedy was unnecessary because the Administrative Record
                              and other documents showed that drinking water contamination was within the
                              standard and future risk of contamination above the standard was unlikely.
                              Thus, the scientific evidence did not support Region 5's decision to fund the
                              remedy.

                            • The air stripper, for which the money was sought, could not even be built
                              because of well construction deficiencies and because the well was under the
                              direct influence of surface water. Installing an air stripper would have violated
                              both Federal and Michigan Safe Drinking Water Acts.

                            • Region 5 and Michigan used an incorrect total cost to determine their respective
                              cost matches for an air stripper, resulting in Region 5 overpaying the State by-
                              Si 23,800.

                           We issued our final report (2001-P-00011) on September 14, 2001.  Recognizing
                           that 6 years have passed since Region 5 made an affirmative decision to award
                           $1.238  million, we did not recommend recovery of the total award.  In our view, the
                           true benefit of this report is to serve as a "lessons learned" document for future
                           Superfund decisions. Region 5 did agree with our recommendation  to recover the
                           costs associated with the $123,800 overpayment, and indicated it would seek
                           recovery. A response to the final report is due December 14, 2001.
 Region 2's
 Institutional
 Controls Were
 Effective
Region 2 adequately made use of institutional controls (ICs) at Superfund sites to
ensure that public health and the environment were protected. ICs are non-
engineering measures (usually legal controls) intended to affect human activities so
as to prevent or reduce exposure to hazardous substances.  EPA has recently
emphasized these controls as an important aspect of the Superfund program.

We reviewed 14 sites and found that 8 had ICs in place, while the remaining 6 had
decided on ICs but had not yet implemented them. ICs were effective in all cases
where they were implemented. For example, at one site, where ICs covered land
and water use restrictions, the county health department received a call that led to it
preventing the use of well water for five new houses because ground water was still
contaminated. At another site, an EPA Remedial Project Manager found large holes
around a site cap that appeared to have been dug by dogs, and then arranged to have
the holes filled and preventive measures implemented.

Despite the effectiveness of ICs, we noted some areas where improvements could be
made.  State and regional staff indicated that the interval between the 5-year reviews
was too long. New York and New  Jersey monitor their sites on annual and 2-year
cycles, respectively,  and we consider those time frames better. In addition, we
identified the need for additional training  of regional staff on the awareness and use
of ICs.
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                         We recommended that the Region 2 Administrator have staff conduct interim
                         reviews at least every 18 months and that additional training courses be developed.
                         Region 2 generally concurred with our recommendations.  We issued our final
                         report (2001-M-00021) on August 29, 2001. A response to the report is due
                         November 19,2001.
Former Air
Authority Board
Member Sentenced \
On April 26, 2001, Richard W. Canestraro, a former North Ohio Valley Air
Authority (NOVAA) board member, was sentenced in U.S. District Court, Southern
District of Ohio, for aiding and abetting the acceptance of an unlawful gratuity' and
conspiracy to defraud the United States. Canestraro was sentenced to 1  year and
1 day in prison, 1 year supervised release, and ordered to pay a $10,000 fine and
$100 special assessment.

Earlier, in March 2001, Patsy J. DeLuca, a former Executive Director of NOVAA,
and Vincent R. Zumpano, a former NOVAA employee, were both sentenced in the
same court. DeLuca was sentenced for accepting an unlawful gratuity and
conspiracy to defraud the United States. He was sentenced to 4 months in prison,
4 months of which were to be served in home detention; 2 years probation; and
ordered to pay a $10,000 fine and $200 special assessment. Zumpano was
sentenced for aiding and abetting the acceptance of an unlawful gratuity and
conspiracy to defraud the United States. He was sentenced to 15 months in prison,
2 years probation, and ordered to pay a $8,000 fine and $200 special assessment.

Prior to disbanding, NOVAA was a multi-county air quality regulator}7 agency
headquartered in Steubenville, Ohio, that received EPA funds through the Ohio
Environmental Protection Agency to enforce federal and state air quality laws.
While DeLuca was Executive Director, he agreed to accept $169,750 from Pine
Hollow C&D Landfill and RSV, Inc., for advising them on pending applications
before the Ohio EPA for new or expanded sites. Canestraro, in return for $3,500,
aided DeLuca by producing a cost projection regarding disposal permits which
facilitated DeLuca's agreement with Pine Hollow and RSV. Zumpano also aided
DeLuca in the agreement.
Environmental
Firm Sentenced
for Issuing
Fraudulent
Training
Certificate
On April 13, 2001, F&M Environmental Technology, Inc. (F&M Environmental),
and its president, Frankland P. Babonis, were sentenced in U.S. District Court,
Eastern District of Virginia, for issuing a fraudulent asbestos training certificate.
F&M Environmental was sentenced to 2 years probation and ordered to pay a
$30,000 fine and $400 special assessment. Babonis was sentenced to two 15-month
jail terms, to be served concurrently; 3 years probation; and ordered to pay a
$4,000 fine and $200 special assessment.
                                                           PAGE 7-APRIL 1. 2001 THROUGH SEPTEMBER 30,2001

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                          The sentencing followed guilty pleas entered by F&M Environmental and Babonis
                          on February 9, 2001.  F&M Environmental pled guilty to one count of false
                          statement and Babonis pled guilty' to one count each of false statement and mail
                          fraud.  In their plea agreements, the defendants admitted to knowingly issuing an
                          individual working with asbestos materials a fraudulent certificate of completion of
                          training required by Section 206 of the Toxic Substances Control Act.

                          The false certificate stated that the individual had completed the requisite training
                          for asbestos accreditation and satisfactorily passed an examination covering the
                          contents of the continuing education course, "32 Hour EPA Workers Asbestos
                          Abatement Training Program," when, in fact, the individual had never taken such a
                          course nor satisfied any requirements of the certified training program.

                          Babonis also engaged in a scheme to defraud Phoenix Enviro Corporation (PEC) of
                          Wilmington, North Carolina, by issuing fraudulent certificates to PEC employees
                          without providing any training to those employees.  After mailing the false
                          certificates to PEC, F&M Environmental would then bill PEC for the cost of
                          training when, in fact, no  such training had been done.

                          The fraudulent schemes undercut state laws designed to protect workers and the
                          public from health risks by requiring workers to be properly trained and certified to
                          remove, handle, and dispose of asbestos-containing material.

                          This investigation was conducted jointly by the EPA OIG, the Federal Bureau of
                          Investigation, and the Navy Criminal Investigative Service.
 Former Contract
 Lab Employees
 Plead Guilty
Five former employees of Intertek Testing Services Environmental Laboratories,
Inc. (ITS), of Richardson, Texas, pleaded guilty in U.S. District Court, Northern
District of Texas, to making false demands against the United States.

On September 26, 2001, the defendants admitted in their plea agreements that they
knowingly caused a false claim to be submitted against the United States by
submitting a data package reflecting the false analysis of an environmental sample.
The guilty pleas were entered by Melissa K. Duncan, Group Leader; James Neil
Mayhew, Manager; Victor DeAnthony Littles, Senior Chemist; Rodney L. Roland,
Chemist; and Valerie Hong Truong, Chemist.

The guilty pleas came after a 30-count indictment handed down on September 21,
2000, in which the company's vice president and 12 former employees were
charged with altering test data, falsely certifying equipment calibrations, presenting
false laboratory reports, and making false representations about the analysis of
environmental samples. The eight other individuals are awaiting trial.
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                          ITS, formerly known as NDRC Laboratories, Inc., and Inchcape Testing Services
                          Environmental Laboratories, Inc., is a full service environmental testing laboratory
                          that generated $35.7 million in gross billings and performed environmental sample
                          analysis on more than 59,000 separate environmental projects involving over
                          250,000 samples of air, soil, liquids, pesticides, explosives, and nerve/chemical
                          agents. These analyses were conducted to determine, among other things, the
                          presence of known or suspected cancer-causing contaminants.

                          This investigation was conducted jointly by the EPA OIG, the EPA Criminal
                          Investigation Division, the Defense Criminal Investigative Service, the United States
                          Army Criminal Investigation Command, and the Air Force Office of Special
                          Investigations.
Company
Exposing Workers
to Health Risks
Sentenced and
Fined
On August 24, 2001, Construction Personnel, Inc. (CPI), as well as two of the
company's officers and two other employees, were sentenced in U.S. District Court,
Eastern District of Tennessee, for bringing in and harboring aliens, conspiracy, and
making false statements and claims.  CPI, also known as Services Management, Inc.
(SMI), was sentenced to 3 years probation and ordered to pay $328,286 in
restitution to the Department of Health and Human Services (HHS) and a special
assessment of $5,250.

The company's president, Mark Weaver, was sentenced to 3 years probation and
ordered to pay a portion of the restitution to HHS, a $7,500 fine, and a $300 special
assessment. The vice president, Ron Goodwin, was sentenced to serve 1 year and a
day in jail, 2 years probation, 150 hours of community service, and ordered to pay a
portion of the restitution to HHS and a $300 special assessment.  Tina Voiles, a
payroll clerk, was sentenced to one year probation, and ordered to pay a $500 fine
and a $10 special assessment. Earlier on July 26, 2001, Maria Shumaker, Manager,
SMI of Baton Rouge, Louisiana, was sentenced in U.S. District Court, Middle
District of Louisiana, to 2 years probation, and ordered to pay a $1000 fine and a
$10 special assessment.

The defendants provided hourly workers, the majority of whom were unauthorized
aliens, to various construction and demolition contractors to include contractors
who performed asbestos abatement work. The defendants provided the aliens or
assisted them in obtaining false asbestos training certificates, licenses, and social
security cards.

This investigation was conducted by the EPA OIG as part of the Tennessee
Environmental Crimes Strike Force.
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 Goal 2: Improve EPA's Management and Program Operations
                        The OIG assesses EPA's management and program operations to
                        identify best practices, areas for improvement, and cooperative
                        solutions to problems.  The OIG's work is designed to promote
                        efficiency and effectiveness within EPA.  The following represent
                        some examples of the more significant efforts under this OIG
                        goal.
 EPA's Planning
 and Funding for
 Protecting
 Infrastructure
 Need Improvement
We found that EPA had addressed a number of key Presidential Decision Directive
(PDD) 63 requirements for protecting the Agency's critical physical infrastructures,
as well as the nation's water supply systems, in the event of a debilitating situation,
such as a terrorist attack. However, we noted several aspects of planning and
funding need to be addressed. Subsequent to the publication of our report, EPA
indicated it is revisiting its PDD 63 efforts in light of the terrorist attacks on
September 11,2001.

PDD 63, initiated in May 1998, required each Federal agency to review its own
critical physical infrastructures (staff, systems, and facilities) needed to perform its
mission in the event of a debilitating situation. PDD 63 also required EPA, in
conjunction with the private sector, to establish a national framework for protecting
the physical infrastructure of the nation's water supply systems in emergency
situations.

Despite the many actions taken, we found that the Agency did not address certain
aspects of planning that may be needed to maintain its ability to protect its critical
physical infrastructures. Also, funding problems caused delays in attempts by EPA
and the private sector to develop a national framework for protecting the critical
infrastructure for the nation's water supply.  Consequently, some key PDD 63
requirements, such as conducting vulnerability assessments and risk mitigation, as
well as implementing a Vulnerability Awareness and Education Program for the
water sector, have yet to be achieved.

We issued our final report (2001-P-00010) on June 25, 2001. We made
recommendations to complete PDD 63  activities in process, fill gaps in critical
infrastructure planning, and address resource needs. In response to our draft report,
the Agency generally agreed with our conclusions and recommendations.

A response to our final report was due by September 25, 2001. However, in light of
the events of September 11, the Agency requested additional time to review its
approach to counter-terrorism and set specific, meaningful, and targeted milestones
based on the current context. We granted the Agency additional time to prepare its
final response.
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Competition
Needed in
Awarding
Assistance
Agreements
EPA does not have a policy requiring competitive awarding of discretionary
assistance funding, even though such a policy would be beneficial and is used by
other entities, such as the Departments of Health and Human Services and
Commerce.  Competition is essential to ensure EPA awards funds to the most
qualified organizations at the least cost.  However, EPA often awards noncompetitive
assistance agreements based on the unsupported belief that recipients were the only
entities capable of performing the work.

In fiscal year 1999, EPA awarded about $4 billion of assistance funds to state and
local governments, tribes, nonprofit organizations, universities, and others. Of this
amount, $2.7 billion was awarded for continuing environmental programs and not
subject to competition. However, we believe that a significant portion of the
remaining $1.3 billion could have been competed. EPA disagreed, and estimated
that about $200 million of fiscal year 1999 awards were actually competed.

EPA officials awarded some assistance funds without competition because they
considered the grantee "uniquely qualified," but these assertions were based on the
project officers' beliefs without adequate justifications. We also found implications
of preferential treatment in the selection of grantees based on EPA's history with the
grantee. An evaluation of whether another grantee could also do a good job, but at a
lower cost, was not done. Further, program offices generally could not provide
information to support that annual funding priorities were established and advertised,
to ensure awards complement program objectives.

We recommended that EPA (1) issue a policy requiring that assistance agreements be
competed to the maximum  extent practicable, (2) prepare written justifications for
noncompetitive awards, and (3) ensure annual funding priorities are established and
advertised for each assistance program.

We issued our final report (2001-P-00008) on May 21, 2001.  EPA responded to the
report on August 22, 2001 and issued a supplemental response on September 19,
2001. In response, EPA drafted an Order that lists those assistance programs for
which competition is inappropriate and, for the remaining programs, will require
competition unless program offices provide a credible written justification for a non-
competitive award. EPA stated that the Order will apply to new assistance
agreements awarded on or after October 1, 2002.
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 National
 Association of
 Minority
 Contractors
 Misspent EPA
 Funds
We determined that of the $712,041 in EPA's share of costs incurred by the National
Association of Minority Contractors (NAMC) under an EPA grant, $456,873 was
ineligible and $141,237 unsupported.  Subtracting the $113,931 in acceptable costs
incurred from the $750,000 actually paid to NAMC, we concluded that a balance of
$636,069 was due EPA from NAMC.

In 1995, NAMC, a Washington, DC organization, had received $750,000 in EPA
funds under Grant No. X-824519-01 to oversee monitoring of state efforts to assist
minority firms in obtaining contracting opportunities, and to perform outreach on
environmental justice activities. The grant was managed by EPA's Office of Small
Disadvantaged Business Utilization (OSDBU).

In 1998, OIG had performed an audit of this grant because of an anonymous
complaint alleging NAMC poor performance and mismanagement.  In August 1999,
we issued a report, Audit  Report on the National Association of Minority
Contractors, which disclosed that although NAMC completed only a small portion of
the required work, OSDBU allowed NAMC to draw down all of the $750,000 in
grant funds.

We recommended that the Director, Grants Administration Division adjust the
allowable costs and instruct NAMC to repay EPA the $636,069. We issued the final
report (2001-1-00203) on September 27, 2001. A response to the final report is due
December 26, 2001.
 Region 3 Needs to
 Ensure All NPT>ES\
 Permits Meet
 Standards
Several states in EPA's Region 3 issued permits under the National Pollutant
Discharge Elimination System (NPDES) that did not ensure that facilities met water
quality standards under the Clean Water Act. In some cases Region 3 acquiesced in
the issuance of weak permits, resulting in poor water quality and public health risks.
Specifically, we found that some permits:

•  Lacked specific discharge limits.
   Were inappropriately modified.
•  Provided for studies rather than limits.
•  Contained vague and complicated language.
•  Did not meet all federal regulatory requirements.

We recommended that Region 3 object to permits not meeting statutory and
regulatory requirements, and use its authority to issue permits when states do not
satisfy regional objections. Region 3 generally agreed with our recommendations but
supported its current NPDES permit oversight practices.

We issued the final report (2001-P-00012) on June 25, 2001, and received Region 3's
response on September 20, 2001. Region 3 generally agreed with our
recommendations and has begun to take corrective actions.
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Lack of Oversight
Fosters Computer
Security
Weaknesses
The absence of computer security oversight in the Agency has led to weaknesses in
many aspects of its computer security program and practices, including: risk
management, incident handling, capital planning and investment, enterprise
architecture, infrastructure protection, and technical controls. Despite EPA's efforts
to improve its computer security program, in accordance with the Government
Information Security Reform Act, problems in these areas continue.

EPA's decentralized structure increases the importance of deploying a coordinated,
comprehensive monitoring program.  However, until EPA implements regular and
effective oversight processes, management will continue to place unsubstantiated
trust in its many components to fully implement and document security
requirements.  Moreover, the public and Congress may continue to question how
well the Agency plans for and protects its information resources to ensure the
integrity, confidentiality, and availability of environmental data.

We recommended that EPA  develop and implement an agency-wide strategy for
monitoring major aspects of its  computer security program and allocate sufficient
resources to routinely administer and verify the effectiveness of oversight processes.
By doing so, the Agency should be able to detect and help alleviate the above-
mentioned security program weaknesses.

We issued our final audit report (2001 -P-00016) to the EPA Administrator and the
Office of Management and Budget on September 7, 2001, in accordance with the
Government Information Security Reform Act. The Agency simultaneously issued
an executive summary of its annual review findings that reported similar weaknesses.
Per Office of Management and Budget requirements, the Agency must submit a
strategy by October 31,  2001, including a time-phased action plan, to correct the
identified security weaknesses.
EPA to Disclose
Penalty
Information to IRS \
EPA agreed to provide penalty information to the Internal Revenue Service (IRS)
under a 1989 agreement. Without the deterrent effect of penalty disclosure to IRS,
violators who include nondeductible penalties as business expenses on their income
tax returns may reduce their tax liability with less chance of detection by IRS
auditors. The reporting also helps to deter future environmental violations.
However, we found that EPA had discontinued the disclosure of penalty information
to IRS.  The reason for the discontinuance was unclear.

According to EPA's accounting records, the Agency annually assessed an average of
$82 million in penalties from October 1, 1997 to May 24, 2001. If the violating
companies deducted these penalty payments as business expenses on their corporate
income tax returns (assuming nondeductible penalties and a 35 percent corporate
income tax rate), this could have resulted in an annual revenue loss of $28.7 million
to the U.S. Treasury. As a result of OIG's review of EPA penalty collections, EPA
agreed to resume the disclosure of EPA penalty information to IRS.
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                         We recommended that EPA meet with IRS officials to update the terms of the
                         agreement, and resume the disclosure of penalty information to IRS. Both EPA and
                         IRS agreed. We issued our final Special Report (2001-S-00011) on September 21,
                         2001. A response to the final report, to provide specifics on planned actions, is due
                         by December 20, 2001.
 Three Indicted for
 Conspiring to
 Embezzle Funds
 from Tribal
 Organization
On April 24, 2001, Estelole Goings, Carol Vitalis, and Vonnie Goings were each
indicted in U.S. District Court, District of South Dakota, Western Division, on one
count of conspiracy and four counts of embezzlement and theft from an Indian tribal
organization.

Estelole Goings was the payroll supervisor in the payroll department of the Financial
Accounting Office for the Oglala Sioux Tribe, Pine Ridge Reservation, Pine Ridge,
South Dakota.  Her duties included preparing payroll and payroll-related reports, and
issuing paychecks to tribal program directors for distribution to employees. Vonnie
Goings, daughter of Estelole Goings, and Carol Vitalis were payroll technicians
supervised by Estelole Goings.

The indictment charges that Estelole Goings conspired with her daughter and Vitalis
in a scheme to  make unauthorized payroll and overtime advances to themselves and
other tribal employees in the accounting office. They furthered the scheme by
creating a false job classification to conceal the theft. The conspiracy, which took
place between February 1996 and October  1998, resulted in the embezzlement of
approximately  $115,000 in EPA and other grant funds awarded to the Oglala Sioux
Tribe.

This investigation was conducted jointly by the EPA OIG, the U.S. Department of the
Interior, and the Bureau of Indian Affairs.
 Conservationist
 Sentenced for
 Theft
On May 31, 2001, Esperanza Asuncion, a former Secretary/Treasurer of the West
Maui Soil and Water Conservation District, was sentenced in Circuit Court of the
Second Circuit, State of Hawaii, to 5 years probation, 500 hours of community
service, and ordered to pay $47,900 in restitution. The sentencing follows
Asuncion's guilty plea on February 13, 2001, to one count of theft in the first degree
and nine counts of forgery in the second degree.

The conservation district is a non-profit organization that received EPA funds
through Section 319 (Non Point Source) grants awarded to the State of Hawaii.
Asuncion diverted funds from the conservation district by forging the chairperson's
signature on a number of checks written against the conservation  district.

This investigation was conducted jointly by the EPA OIG and the Hawaii State's
Attorney General  Office.
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Former University
Official Sentenced
for Embezzlement
On August 24, 2001, Gerald Todd Burd was sentenced in U.S. District Court,
District of Kansas, for embezzling funds from a non-profit foundation and private
trust fund. Burd was sentenced to 1 year and 1 day in prison and ordered to pay
$440,528 in restitution.

Burd, a former comptroller of the Haskell Foundation, Haskell Indian Nations
University, admitted in a May 9, 2001, plea agreement that from January 1998
through December 1999, he wrote $440,528 in checks payable to himself against the
two funds he was operating. Of that amount, he embezzled $103,979 from the
Haskell Foundation, which receives funding from various environmental justice
grants, and $336,549 from a private trust fund Burd administered.

This investigation was conducted jointly by the EPA OIG and the Federal Bureau of
Investigation.
 Trade Association
Repays Grant
Funds
On May 15, 2001, the Operative Plasters' & Cement Masons' International
Association (OP&CMIA) reimbursed EPA $25,000 to resolve a potential false
claims suit. In September 1994, OP&CMIA was awarded an EPA grant valued at
$175,000 to provide lead abatement training to an estimated 180 members. It was
later determined through an OIG audit and investigation that OP&CMIA drew down
on all of the grant funds but actually trained only 51 students.

The OP&CMIA is comprised of 38,000 members employed in the trades of
plastering and cement finishing work. OP&CMIA had subcontracted with the
University of Maryland at Baltimore,  School of Medicine, and the Occupational
Health Foundation to provide the training.
EPA Employee
Charged in
19-Count
Indictment
On May 23, 2001, Luther E. Mellen III, a branch chief in EPA's Facilities
Management and Services Division, was indicted in U.S. District Court, District of
Columbia, on charges of conspiracy to defraud the United States and receipt of stolen
government property. Mellen was indicted along with 11 other individuals,
including his wife, Elizabeth, and 8 other family members. Additional charges
against the various other individuals included theft of government property, selling
stolen government property, and conspiracy to defraud the United States with respect
to false claims.

The 19-count indictment was the result of a lengthy investigation in connection with
a large Department of Education (DOEd) contract with Bell Atlantic.  The indictment
charges that from about early 1990 to December 1999, Mellen's wife, Elizabeth
Mellen, a telecommunications specialist in  the Office of the Chief Information
Officer, DOEd, used her position as a contract officer's technical representative on
the Bell Atlantic contract to procure over $300,000 in computers, printers, cellular
phones, cameras. Palm Pilots, and a 61-inch television for personal use.
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                         Based on the indictment, an arrest warrant was issued for Luther Mellen, a co-
                         conspirator for receiving stolen goods.  Luther Mellen was placed under arrest and
                         subsequently released on his own recognizance.

                         This investigation was conducted jointly by the EPA OIG, the Department of
                         Education  OIG, and the Federal Bureau of Investigation.
 EPA Employee
 Sentenced in Theft
 of Credit Card
On May 1, 2001, Tia M. Newman, was sentenced in U.S. District Court, District of
Columbia, to  three 180-day suspended sentences, 3 years probation, and ordered to
pay $4,328 in restitution to the EPA and a $125 special assessment. In addition,
Newman resigned from her EPA position. Newman, a former clerk typist in the
Office of Environmental Justice, Office of Enforcement and Compliance, pleaded
guilty to a criminal information  charging her with one count of receiving stolen
property and two counts of theft. Newman admitted in her plea agreement that in
November 1998 she removed and activated a government credit card from the office
mail that was intended for a co-worker who had retired earlier that year. Newman
used the credit card to make numerous personal purchases from a local toy and
clothing store.
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Goal 3: Produce Timely, Quality and Cost-Effective Products and Services That
         Meet Customer Needs
                       The OiG is a customer-driven organization in which customer
                       needs serve as the basis for work planning and the design of OIG
                       products and services.  All OIG work is based on anticipated
                       value to Congress and EPA, The following represent some
                       examples of the more significant efforts under this OIG goal.
OIG, Region 2
Collaborate to
Develop Corrective
Action Plan for
Puerto Rico Board
OIG and Region 2 recently collaborated to develop a Corrective Action Plan for the
Puerto Rico Environmental Quality Board (PREQB) after a joint survey by OIG and
Region 2 disclosed serious problems with PREQB's grant and financial management
systems.

During the survey stage of OIG's review of PREQB's grant/financial management,
Clean Air Act Title 5 management, and Clean Air Act enforcement, we invited
Region 2 staff to participate as part of the team, and they accepted. The joint survey
disclosed that after years of EPA providing funding and technical assistance to
address PREQB's grant and financial management system deficiencies, the
organization remained in complete disarray.  PREQB lacked a financial management
system sufficient to adequately account for and safeguard grant dollars. With the
lack of control over grant funds, permit fees, and expenditures of ear-marked funds,
as well as other problems,  PREQB had an environment ripe for fraud.

Many of the deficiencies cited were not new, as financial management and
accounting deficiencies have plagued PREQB for years.  Some problems noted as a
result of a prior Corrective Action Plan continue to exist. For example, PREQB
abandoned a multi-year effort to implement an acceptable accounting system that
was in progress up until recently; as a result, PREQB is currently operating without
an accounting system of any kind.  The team also reported that PREQB did not have
sufficient knowledge on assistance agreements to comply with guidance, and could
not provide assurance that Title 5 permit fees had been collected and collected fees
safeguarded and used solely for Air activities.

To address these issues, OIG collaborated with Region 2 on developing a Corrective
Action Plan containing numerous recommendations.  In June 2001, the Acting
Region 2 Administrator and OIG jointly issued an Official Letter to PREQB
classifying the Agency as a High Risk Grantee. PREQB's letter of credit
authorization was terminated as a result.  The letter also cited immediate steps that
PREQB must take to rectify the deficiencies noted, with due dates. The
OIG/Region 2 team briefed both Region 2 and OIG senior management to explain
the need for immediate action being taken with the grantee.
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 Corrective Actions
 Under Federal
 Financial
 Management
 Improvement Act
 Ongoing
The EPA Chief Financial Officer continues to address planned corrective actions
included in its fiscal 1999 Remediation Plan submitted to the Office of Management
and Budget on November 13, 2000, under the Federal Financial Management
Improvement Act. Included in EPA's Remediation Plan were planned actions in four
major areas:

•   Financial Statements Preparation Process
•   Federal Trading Partner Information
•   Financial System Security Plan Improvements
•   Compliance with the Managerial Cost Accounting Standard

Progress has been noted by  the Office of the Chief Financial Officer (OCFO) in each
of these four areas.  EPA prepared and submitted its FY 2000 Financial Statements
on the statutory due date of March 1, 2001, and received a clean audit opinion.  The
Agency will  continue to improve its preparation process and is automating major
portions of the process for the FY 2001 financial statements.

In addition, EPA has completed all of the corrective actions for the Federal Trading
Partner Information requirements,  including steps to ensure that beginning balances
are accurate, and policies and procedures are implemented for confirming and
reconciling balances with trading partners.

The OCFO's original Remediation Plan for security set an aggressive, multi-year
schedule for  correcting existing security deficiencies, but the estimated completion
date of June  2002 for all actions will not be met in some instances. Some slippages
have occurred in financial- and mixed-financial  systems' security due to contractor
delays beyond OCFO's control. To accommodate these slippages, the Remediation
Plan is being updated and will be submitted as part of EPA's fiscal 2003 budget
submission to the Office of Management  and Budget.

We again reported noncompliance with the managerial cost accounting standard in
our fiscal 2000 financial statement audit.  The Chief Financial Officer, while
acknowledging the desirability for continuing improvements as envisioned by the
standard, continues to disagree with our conclusion that EPA did not comply with  the
standard. Because of this impasse, we plan to elevate this issue to the Administrator
for resolution, as is required by the Federal Financial Management Improvement
Act. We are evaluating the adequacy of completed actions as part of the fiscal 2001
financial statement audit.
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Advocacy Group
Continues to
Mismanage EPA
Funds
 The National Asian Pacific Center on Aging (NAPCA) continues to have significant
 problems in administering EPA cooperative agreements, OIG noted in an advisory
 report recently issued following a Region 10 request.

 NAPCA is a national advocacy organization for older Asian Pacific Americans based
 in Seattle, Washington. In reports dating back to 1998, OIG had noted numerous
 problems with NAPCA's cash management and that sufficient corrective actions
 were not being taken. In fact, a March 2001  OIG report advised EPA of the
 embezzlement of $1.8 million by an NAPCA employee.

 In our advisory report (2001-S-00012), issued September 26, 2001, we noted that
 NAPCA continues to demonstrate a serious inability to properly manage its EPA
 awards, draw grant funds only to meet immediate cash needs, and comply with
 financial reporting requirements. We recommended that the Office of
 Administration and Resources Management review EPA awards to NAPCA for
 potential termination, recover excess cash drawn by NAPCA, and require that
 NAPCA be placed on a restricted payment program. We also recommended that
 EPA not award any further agreements to NAPCA or make amendments to existing
 agreements until  appropriate changes are made. A response to the advisory report is
 due November 27, 200].
EPA's Progress in
Using GPRA to
Manage for
Results Evaluated
The EPA OIG reviewed EPA's success in implementing the Government
Performance and Results Act (GPRA) to
manage for environmental results,
focusing on the Agency's progress in
using GPRA, challenges  in
implementing GPRA, and opportunities
for near and long-term improvements.
The diagram demonstrates the six critical
aspects of GPRA implementation and
their interlocking, mutually dependent
relationships as a framework for this
evaluation.

The review indicated that, to improve
GPRA implementation and overall
effectiveness and efficiency, EPA must strengthen its partnerships with states and
other agencies.  Also, EPA needs to place greater focus on the ultimate results and
outcomes of its activities rather than actions performed, and should more carefully
consider science and cost in addition to laws and public perceptions when setting
priorities. Additionally,  EPA needs to invest in management, scientific and technical
competencies of its staff, as well developing and integrating quality performance and
cost information into its budgeting, decision-making and accountability systems.
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 OIG Employee
 Recognized by
 Region 9 for
 Assistance
Consulting services provided to EPA Region 9 by an OIG auditor in our San
Francisco office were recently recognized by the Region 9 Deputy Regional Counsel
in an award nomination for the OIG employee.

During the last several years, Paul Jalbert has provided consulting services to the
Region 9 Office of Regional Counsel and program offices in determining the validity
of claimed inabilities to pay proposed penalties.  Services provided included analysis
of financial data submitted by respondents, assistance in identifying needed
information, assistance in negotiations, and expert testimony at Administrative Law
Judge hearings.

The Deputy Regional Counsel commented in the award nomination that the Jalbert's
"... expertise, analytical skills and insight proved critical to our successful
prosecution of a number of enforcement cases. His assistance has been far-ranging,
from providing in-depth analyses of ability-to-pay claims from various defendants to
providing crucial testimony as a expert witness ....  He works closely and
collaboratively with the Office of Regional Counsel and the media programs."
 OIG and Office of
 Environmental
 Information
 Developing
 Computer
 Intrusion Response
 Protocol
The EPA OIG's Computer Crimes Unit has been providing consulting services to the
Office of Environmental Information (OEI) to develop incident response handling
guidelines for Agency personnel to use when responding to a suspected computer
intrusion incident.

The OIG Computer Crimes Unit, in cooperation with OEI and EPA program offices
and regions, has formed the Computer Crimes Consultative Working Group. The
working group, chaired jointly by the Computer Crimes Unit and OEI, is comprised
of the Agency's Information Security Officers (ISO), representatives from the
Agency's Office of General Counsel, and the OIG's Office of Counsel and Office of
Investigations. The working group is tasked with, among other things, identifying
the training needs of the ISO community for responding to possible computer
incidents and to develop proposed  responses to those training needs.  Charettes, or
temporary sub-working groups, have been formed to examine issues and provide
suggestions, advice, and opinions to improve Agency computer security. Currently,
charettes are examining the Agency's banner, developing an ISO checklist for
responding to computer incidents,  and evaluating a training program for Agency
personnel in the areas of electronic privacy, monitoring, and related legal issues.
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Goal 4: Enhance Diversity, Innovation,  Teamwork and Competencies
                       The OIG is committed to becoming a high performance
                       organization by recruiting and maintaining a diverse and highly
                       competent workforce.  The OIG promotes continuous learning and
                       is expanding its use of technology and mufti-discipline teams.
                       The following represent some examples of the more significant
                       efforts under this OIG goal.
JIB^M^MBBBBBB The OIG initiated a special diversity training course during the past reporting period
OfG Implements   I that was specially tailored by its own personnel to enhance awareness; improve
Diversity Training I communication; and enlighten the OIG staff on the value, benefits, and rewards
                       gained from a multicultural and diverse workforce.

                       The training, devised by Special Emphasis Program Managers located at various
                       locations within the OIG, is geared toward having participants share knowledge and
                       experience with each other that will ultimately improve individual and organizational
                       work performance.

                       The course has been designed to: promote awareness of diversity through interactive
                       training, develop a workforce that will encourage and embrace diversity, and build
                       understanding within the organization of the benefits created by a diverse workforce.

                       The goals and objective of the training are:

                       •  Value Everyone: Provide training and knowledge for all  employees to promote
                          a workforce aware of the diverse qualities that determine  the merit, usefulness,
                          and importance of each employee.

                       •  Open Communications: Build and maintain effective relationships within the
                          OIG to promote a greater understanding of different cultures and raise the value
                          and awareness of diversity in the workplace.

                       •  One OIG: Plan and coordinate various educational events to foster better
                          awareness and appreciation of cultural, personality, and skill set differences of
                          all employees so the EPA OIG can function better as a whole unit.

                       All OIG employees have either taken the one-and-one-half day training or are
                       planned to do so by the end of 2001.
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 EPA OIG
 Investigators Help
 in Massive World
 Trade Center
 Probe
Three investigators for the EPA OIG who are stationed in New York City have been
playing a small part in helping with the massive investigation that followed the
terrorist attack on that city's World Trade Center Twin Towers.

Following the attack,  these investigators helped sort through Trade Center rubble that
had been transported to a landfill in Staten Island, looking for evidence that could be
used in the investigation or to help identify victims.

"There was a tremendous need for people with expertise, and this was a time for us
to contribute," said Paul Zammit, the OIG's Divisional Inspector General for
Investigations for the  Eastern Investigations Division. "We were small players in a
huge effort being carried out by thousands of law enforcement officials."

Zammit said they focused on finding items that would help in the probe, such as
airplane parts, as well items such as wallets that could help identify victims.  "We're
trying to bring closure to the families," Zammit said.

Starting on September 13, Zammit and OIG Special Agents Paul Brezinski and Bart
George helped in the  investigative effort.  Their office is located about six blocks
from the World Trade Center site, and for the week and a half they were on
administrative leave due to their office being  closed they provided the assistance.
They are continuing to help out on weekends, Zammit said.
 Innovative
 Performance
 Measurement
 System Provides
 Scoreboard of
 Strategic Results
The OIG Office of Planning, Analysis, and Results has developed an innovative
approach for implementing the OIG's corporate strategy by creating a Performance
Results and Measurement System to provide a Scoreboard on accomplishments.

Recognizing that what gets measured gets done, this measurement and reporting
system was designed as the enabling tool to promote a results-oriented culture
supporting the OIG's strategic goals and high performance objectives. The system is
designed to electronically link, collect, tabulate, and provide timely feedback on a
variety of measures for all OIG products and services as well as customer
satisfaction. The intent is to demonstrate a Scoreboard of progress toward each of the
OIG's four Strategic Goals in a logic model relationship.

Data collection and measurement tools include:

•   Performance Results and Measurement Template and Tabulation System, to
    collect and aggregate measures of OIG progress toward achievement of each of
    our strategic goals and annual targets.
•   An external customer/client survey, to measure satisfaction with OIG products
    and services.
•   An internal customer survey, to measure how well we serve each other.
•   Special purpose surveys, such as SWOT (strengths, weaknesses, opportunities,
    and threats), to help plan and monitor organizational direction and environment.
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   Our goal is to integrate cost, time, internal satisfaction, external satisfaction, and an
   array of business results in a manner that demonstrates our value while providing
   reliable information for effective planning, accountability, and decision making.
Linkage ot'OIG Business Line Measures/Results from Products & Services to Improved
EPA Operations & Impacts: Results compared to resources used = Return on Investment
Questioned Costs/Savings
Recommendations/Opinions
Advice/Analysis/Projects
Indictment/Convictions
Civil/Administrative
Fines/Restitutions
Reports/Briefings
Evaluation Conclusions
  Legislative Change
  Regulatory Change
  Policy Change
  Practice Change
  Enforcement Actions
  Industry, Grantee or
    State Monitoring
$s Recovered, Offset or Avoided
                                                              Improved Efficiencies
                                                              Improved Effectiveness
                                                              Improved Controls
                                                              Increased Compliance
                                                              Improved Reporting
                                                              Risk Reduction
                                                              Improved environmental &
                                                               Health Results
  Above is an illustration of how the results of our work are measured from outputs to outcomes,
  creating a linkage between OIG products and services and environmental impacts and goals.
  Customer surveys provide additional accountability feedback for the quality, timeliness and value
  of our work, as well as information for future product service focus and design.
                                            PAGE 23-APRIL 1, 2001 THROUGH SEPTEMBER 30.2001

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    Audit Report Resolution
    Status Report on Perpetual Inventory of Reports in Resolution Process for Semiannual Period Ending
    September 30, 2001
Report Category
A. For which no management
decision was made by
April 1,2001*
B. Which were issued during the
reporting period
C. Which were issued during the
reporting period that required
no resolution
Subtotals (A + B - C)
D. For which a management
decision was made during the
reporting period
E. For which no management
decision was made by
September 30, 2001
F. Reports for which no
management decision was made
within 6 months of issuance
No. of
Reports
85
239
133
191
70
121
33
Report Issuance
($ in Thousands)
Questioned
Costs
$107,747
5,010
0
112,757
61,144
51,613
46,656
Recommended
Efficiencies
$253
31,911
0
32,164
0
32,164
253
Report Resolution Costs
Sustained
($ in Thousands)
To Be
Recovered
0
0
0
0
$41,201
0
0
As
Efficiencies
0
0
0
0
0
0
0
.
      *Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this report
      and our previous semiannual report results from corrections made to data in our audit tracking system.
HTTPy/WWW£PA.GOV/OIGEARTH-PAGE24

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Status of Management
Decisions on OIG Reports

This section presents statistical
information as required by the
Inspector General Act
Amendments of 1988 on the status
of EPA management decisions on
reports issued by the OIG
involving monetary
recommendations.
As presented, information
contained in Tables 1 and 2 cannot
be used to assess results of reviews
performed or controlled by this
office.  Many of the reports were
prepared by other Federal
auditors or independent public
accountants.  EPA  OIG staff do not
manage or control such
assignments.  Auditeesfrequently
provide additional documentation
to support the allowability of such
costs subsequent to report
issuance.  We expect that a high
proportion of unsupported costs
may not be sustained.
Table 1 - Inspector General Issued Reports With Questioned Costs for Semiannual Period
Ending September 30, 2001
Report Category
A. For which no management decision was
made by April 1,2001 **
B. New reports issued during period
Subtotals (A + B)
C. For which a management decision was
made during the reporting period
i. Dollar value of disallowed costs
ii. Dollar value of costs not disallowed
D. For which no management decision was
made by September 30, 2001
E. Reports for which no management
decision was made within 6 months of
issuance
No. of
Reports
39
27
66
25
17
8
41
16
Questioned Costs *
($ in Thousands)
$107,747
5,010
112,757
61,144
41,201
19,943
51,613
46,656
Unsupported Costs
($ in Thousands)
$35,702
1,488
37,190
21,519
12,914
8,605
15,671
14,183
      Questioned costs include the unsupported costs.

      Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this report and
      our previous semiannual report results from corrections made to data in our audit tracking system.
                                                                PAGE 25-OCTOBER 1,2000 THROUGH MARCH 31,2001

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   Table 2 — Inspector General Issued Reports With Recommendations That Funds Be Put To
   Better Use for Semiannual Period Ending September 30,2001

Report Category
A. For which no management decision was made by
April 1,2001*
B. Which were issued during the period
Subtotals (A + B)
C. For which a management decision was made
during the reporting period
i. Dollar value of recommendations from
reports that were agreed to by management
ii. Dollar value of recommendations
from reports that were not agreed to
by management
iii. Dollar value of non-awards or unsuccessful
bidders
D. For which no management decision was made by
September 3 0,2001
E. Reports for which no management decision was
made within 6 months of issuance
No. of
Reports
1
4
5
0
0

0

0

5
1
Dollar Value
($ in Thousands)
$253
31,911
32,164
0
0

0

0

32,164
253
      * Any difference in number of reports and amounts of questioned costs or recommended efficiencies between this
   report and our previous semiannual report results from corrections made to data in our audit tracking system.
Audits With No Final Action As Of 9/30/01-Which Are
Over 365 Days Past OIG Report Issuance Date
Audits
Programs
Assistance Agreements
Contract Audits
Single Audits
Financial Statement Audits
TOTAL
Total
26
84
17
7
3
137
Percentage
19
61
13
5
2
100
fflTPy/WWWEPAGOV/OIGEARTH-PAGE 26

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Summary of Investigative Results
Summary Of Investigative
Activities
Pending Investigations as
of March 31,2001

New Investigations
Opened This Period

Investigations Closed
This Period

Pending Investigations as
of September 30, 2001
160
 29
 29
160
Prosecutive and
Administrative Actions

In this period, investigative
efforts resulted in 11  convictions
and 10 indictments (does not
include indictments obtained in
cases in which we provided
investigative assistance). Fines and
recoveries, including those
associated with civil actions,
amounted to $3.1 million. Thirty
administrative actions were taken as
a result of investigations.
Resignations          1
New Procedures       3
Compliance
Agreements         1
Reprimands         6
Suspension &
Debarment          10
Recoveries          5
Other              4

TOTAL           30
                      Profiles of Pending Investigations by Type
    General EPA Programs
       Total Cases = 102
                       Superfimd
                     Total Cases = 58
                          18
                                        10 fcxxxx
                                F31
               Contract                |  Employye Integrity  H Other
               Assistance Agreement H  Program Integrity
                                                        PAGE 27 - OCTOBER 1,2000 THROUGH MARCH 31,2001

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 Appendix 1  -- Reports Issued
       THE INSPECTOR GENERAL ACT REQUIRES A LISTING, SUBDIVIDED ACCORDING TO SUBJECT MATTER, OF EACH REPORT ISSUED BY
THE OFFICE DURING THE REPORTING PERIOD AND FOR EACH REPORT, WHERE APPLICABLE, THE DOLLAR VALUE OF QUESTIONED COSTS
AND THE DOLLAR VALUE OF RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE.
                                                                      Questioned Costs
                                                                                              Recommended
                                                                                              Efficienc ies
Report Number Title
2001-P-00017 Interim ROD -Petoskey manufacturing Co.-Ingal
Is Muni. Well
2001-P-00013 STATE ENFORCEMENT EFFECTIVENESS - NATIONAL AU
DIT
2001-P-00014 SEP SURVEY - REGION 6
2001-P-00008 EPA's Competitive Practices for Assistance Aw
ards
2001-P-00016 EPA Computer Security Program Planning & Mana
gement
2001-P-00011 Superfund Interagency Agreements
2001-P-00012 Region Ill's NPDES Program
2001-P-00010 EPA's Implementation of PDD 63
2001-P-00015 Tranguch Gasoline Site
2001-P-00018 OW TMDL Listings
TOTAL PERFORMANCE REPORTS = 10
2001-1-00128 EPA Grants, Dept of Public Works, VI
2001-1-00143 Audit of Missouri State Clean Water SRF
2001-1-00203 NAMC
2001-1-00198 Clean Water State Revolving Fund, June 30, 20
00
TOTAL ASSISTANCE AGREEMENT REPORTS = 4
2001-3-00108 United States Virgin Islands
2001-3-00109 Southern Ute Indian Tribe
2001-3-00110 Ely Shoshone Tribe
2001-3-00111 American lOndian Science and engineering Soci
ety
2001-3-00113 Virgin Valley Water District
2001-3-00114 San Francisco Community College
2001-3-00115 San Francisco Community Colege District
2001-3-00116 Fort Worth, City of
2001-3-00112 Nooksack Indian Tribe
2001-3-00118 California, University of
2001-3-00117 Forest County Potawatomi Community
2001-3-00119 Portland, City of
2001-3-00122 American Farmland Trust
2001-3-00121 Minnesota, University of
2001-3-00120 Susanville Indian Rancheria
2001-3-00123 Taos Pueplo Central Management System
2001-3-00124 Taos Pueblo - Central Management System
2001-3-00125 Taos Pueblo - Central Management System
2001-3-00126 Alliance for the Chesapeake Bay
2001-3-00127 Eight Northern Indian Pueblos Council
2001-3-00128 Laguna, Pueblo of
2001-3-00129 Surface Transportation Policy Project
2001-3-00130 Lower Brule Sioux Tribe
2001-3-00131 Thlopthlocco Tribal Town
2001-3-00132 Sumter County Board of County Commissioners
2001-3-00134 Pennsylvania, University of
2001-3-00133 Pennsylvania, University of
2001-3-00135 Lac Courte Orielles Band of Lake Superior Chi
ppewa
Final Report Ineligible Unsupported Unreasonable (Funds Be Put
Issued Costs Costs Costs To Better Jse)
14-SEP-Ol 123,800

14-AUG-01

22-AUG-01
21-MAY-01

07-SEP-01

22-JUN-01
25-JUN-01
20-JUN-01
29-AUG-01
25-SEP-01
123,800 0 0
ll-APR-01 1,268,874
29-MAY-01
27-SEP-01 456,873 141,237 0
25-SEP-01

456,873 1,410,111 0
04-APR-01
10-APR-01
10-APR-01
10-APR-01

12-APR-01
18-APR-01
18-APR-01
24-APR-01
25-APR-01
25 -APR- 01
25-APR-01
27-APR-01
27-APR-01
27-APR-01
27-APR-01
Ol-MAY-01
Ol-MAY-01
Ol-MAY-01
02-MAY-01
02-MAY-01
03-MAY-01
03-MAY-01
03-MAY-01
09-MAY-01 31,050
10-MAY-01
10-MAY-01
10-MAY-01
ll-MAY-01

 HTTP://WWW.EPA.GOV/OIGEARTH - PAGE 28

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Report Number Title
2001-3-00136 South Alabama, University of
2001-3-00137 Illinois Institute of Technology
2001-3-00138 North Ohio Valley Air Authority
2001-3-00139 Sac and Fox Nation of Oklahoma FYs 98 & 99
2001-3-00140 Iowa Tribe of Oklahoma
Final Report
Issued
ll-MAY-01
15-MAY-01
15-MAY-01
17-MAY-01
22-MAY-01

Ineligible
Costs
205,902
Questioned Costs
Unsupported
Costs

Recommended
Efficiencies
Unreasonable (Funds Be Put
Costs To Better Use)

 2001-3-00141  Shoshone  & Arapaho  Joint  Prog,  of  the  Wind  Ri  22-MAY-01
              ver Reservation
 2001-3-00142  Knox  County                                    24-MAY-01
 2001-3-00143  Eastern Shoshone Tribe of  the Wind River Vail  31-MAY-01
              ey
 2001-3-00145  Shoshone  & Arapaho  Joint  Programs  of the Wind  31-MAY-01
               River Reserv.
 2001-3-00147  Connecticut,  State  of                          31-MAY-01
 2001-3-00144  Duckwater Shoshone  Tribe                       31-MAY-01
 2001-3-00148  Parkinson's  Institute                          05-JUN-01           12,021
 2001-3-00149  Ely Shoshone  Tribe                             06-JUN-01
 2001-3-00151  Duckwater Shoshone  Tribe                       06-JUN-01
 2001-3-00150  Yomba Shoshone Tribe                           06-JUN-01
 2001-3-00152  Northeast States for Coordinated Air Use Mgmt  07-JUN-01
              .,Inc & Affilia
 2001-3-00153  Internation  Council for Local Environmental  I  ll-JUN-01
              nitiatives
 2001-3-00154  Business  for  Social Responsibilty  & BSR Educa  ll-JUN-01
              . Fund
 2001-3-00155  New Hampshire, State of                        13-JUN-01
 2001-3-00156  Greenville Rancheria                           13-JUN-01
 2001-3-00157  Vermont,  State of                              14-JUN-01
 2001-3-00158  Illionois State University                     19-JUN-01
 2001-3-00159  Michigan, The University of                    20-JUN-01
 2001-3-00160  Fall  River, City of                            21-JUN-01
 2001-3-00161  Denver, University  of                          21-JUN-01
 2001-3-00162  Stanford  University                            21-JUN-01
 2001-3-00163  Mississippi  - Institutions of Higher Learning  27-JUN-01
              , State of
 2001-3-00164  West  Virginia, State of                        27-JUN-01
 2001-3-00165  National  Academy of Saiences                   27-JUN-01
 2001-3-00166  National  Academy of Sciences 1999              27-JUN-01
 2001-3-00167  Tledo, The University of                       27-JUN-01
 2001-3-00168  Wyoming,University of                          28-JUN-01
 2001-3-00169  Miami University                               28-JUN-01
 2001-3-00170  ZIA,  PUEBLO OF, NM                             28-JUN-01
 2001-3-00171  ZIA,  PUEBLO OF, NM                             28-JUN-01
 2001-3-00172  TESUQUE,  PUEBLO OF, NM                         29-JUN-01
 2001-3-00173  Clark University                               29-JUN-01
 2001-3-00174  Illinois  Institute of Technology               29-JUN-01
 2001-3-00175  Partners  in Economic Reform, Inc               02-JUL-01
 2001-3-00176  Florida,  State of                              02-JUL-01
 2001-3-00177  Wisconsin, State of                            02-JUL-01
 2001-3-00178  Crittenton Hastings House of the Florence Cri  03-JUL-01
              ttenton League
 2001-3-00179  Yavapai-Prescott Indian Tribe                  05-JUL-01
 2001-3-00180  New Mexico-Energy,Minerals,and Natural Res.  D  10-JUL-01
              ept.,  State of
 2001-3-00181  Chehalis Reservation,  Confederated Tribes of   ll-JUL-01                          24,895
 2001-3-00182  Orangeville,  Village of                        ll-JUL-01
 2001-3-00183  BLACKFEET INDIAN TRIBE OF THE BLACKFEET RESER  ll-JUL-01         16,943
              VATION
 2001-3-00184 Association of U.S. Delegates-Gulf of Maine C  13-JUL-01
              ouncil on Marin
2001-3-00185 Tribal Assoc. of Solid Wste % Emergency Respo  16-JUL-01
             nse
2001-3-00186 Burns Pauite  Tribe,  OR                         16-JUL-01
2001-3-00187  Institute for Sustainable Communities          16-JUL-01
2001-3-00188  Pennsylvania, Commonwealth of                  20-JUL-01
2001-3-00189  Shoalwater Bay Indian Tribe,  Tokeland,  WA      25-JUL-01
2001-3-00190  Pryamid Lake  Paiute Tribe                      26-JUL-01          4,480
2001-3-00191 Sauk Suiattle Indian Tribe                     31-JUL-01
2001-3-00192  Illinois,  State of                              Ol-AUG-01
2001-3-00193 Spokane Tribe of Indians                       Ol-AUG-01
                                                                                       PAGE 29 - APRIL 1,2001 THROUGH SEPTEMBER 30,2001

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                                                                                         Questioned Costs
Report Number
                                   Title
                                                            Final Report
                                                               Issued
                                                                            Ineligible
                                                                             Costs
Unsupported
  Costs
             Recommended
    	 Efficiencies
Unreasonable  (Funds  Be Put
  Costs	To  Better Use)
2001-3-00194 Alabama,  State  of                             Ol-AUG-01
2001-3-00195 Allentown School District                     02-AUG-01
2001-3-00196 Shoshone  and Arapaho  Joint  Programs  -Wind Riv 02-AUG-01
             er Reservation
2001-3-00197 Michigan  - Department of Agriculture, State o 03-AUG-01
             f
2001-3-00198 Chesapeake Bay,  Inc.,  Alliance  for the        08-AUG-01
2001-3-00199 New jersey Institute  of Technology            14-AUG-01
2001-3-00200 Rhode Island and Providence Plantations, Stat 15-AUG-01
             e of
2001-3-00201 Rhode Island and Providence Plantations, Stat 15-AUG-01
             e of
2001-3-00204 Saint Regis Mohawk Tribe                      15-AUG-01
2001-3-00202 Ute Indian Tribe                              15-AUG-01
2001-3-00205 Maricopa  County                              17-AUG-01
2001-3-00207 East helena,  City  of                          17-AUG-01
2001-3-00206 Cascade,  Town of                              17-AUG-01
2001-3-00208 Missouri,  state of                           21-AUG-01
2001-3-00209 Michigan  Department of Environmental Quality  22-AUG-01
2001-3-00211 State of  Iowa                                23-AUG-01
2001-3-00212 Utah, State Of                                23-AUG-01
2001-3-00213 Nebraska,  State of                           23-AUG-01
2001-3-00214 Arkansas  for Medical  Science, University of   30-AUG-01
2001-3-00215 Oklahoma,  The University of,  Norman  Campus    30-AUG-01
2001-3-00203 Temecula  Band of Luiseno Mission  Indians      05-SEP-01
2001-3-00216 Assiniboine & Sioux Tribes                    05-SEP-01
2001-3-00217 San Juan,  City  of                             06-SEP-01
2001-3-00218 Pleasant  Point  Passamaquoddy Tribe            07-SEP-01
2001-3-00219 Burlington                                   ll-SEP-01
2001-3-00220 SHERWOOD  VALLEY BAND  OF POMO INDIANS         ll-SEP-01
2001-3-00221 Pueblo of Nambe, NM                          12-SEP-01
2001-3-00222 Pawnee Nation of Oklahoma                     12-SEP-01
2001-3-00223 Pickens County                                18-SEP-01
2001-3-00224 Lone Tree, City of                           19-SEP-01
2001-3-00225 St. Petersburg,  City  of                       19-SEP-01
2001-3-00226 Parkinson's Institute                        26-SEP-01
2001-3-00227 Clarksburg, City of                          27-SEP-01
2001-3-00228 Great Lakes Commission                       27-SEP-01
2001-3-00229 Wayne State University                       27-SEP-01
2001-3-00230 Solvay, City of                              28-SEP-01
2001-3-00231 Burlington, City of                          28-SEP-01
2001-3-00232 Tyrone, Borough of                           28-SEP-01
2001-3-00233 Tyrone, Borough of                           28-SEP-01
                                                                            538,863
                                                                                             26,863
                 TOTAL SINGLE  AUDIT REPORTS = 124
                                                                             809,259
                                                                                               51,758
2001-1-00156 EQMI 1999
2001-1-00170 TRC-EC FY 97 Incurred Cost
2001-1-00177 ECOLOGY & ENVIR 95 Incurred Cost
2001-1-00182 TRC-EC FY 98 Incurred Cost
2001-1-00190 Earth Tech-Incurred Costs(FY97)
2001-1-00192 Earth Tech-Incurred Costs(FY98)
2001-1-00195 ECOLOGY t ENVIR FY 96
2001-1-00199 MPI 1994 Incurred Costs
2001-1-00200 MPI 1995 Incurred Costs
2001-1-00201 ECOLOGY & ENVIR FY97
2001-1-00204 ROSS AND ASSOCIATES
2001-1-00205 ECOLOGY i ENVIR FY 98
2001-1-00202 ICF Consulting Group, Inc.  - CY 2001
              ck
2001-1-00197 ICF Consulting Financial  Capability
25-JUN-01
17-JUL-01
20-JUL-01
15-AUG-01
28-AUG-01
29-AUG-01
18-SEP-01
25-SEP-01
25-SEP-01
26-SEP-01
27-SEP-01
28-SEP-01
Floorche 27-SEP-01
400,877
184,407
120,888
257,111
0
47,306
91, 660
0
0
57,110
5,126
46,279

0
0
20,788
0
0
0
0
0
0
0
0
3,222

0
0
208,839
0
0
0
86,800
0
0
97, 593
0
92,391

0
0
0
0
0
0
0
0
0
1,
0
1,










545, 107

666, 379

                                                             20-SEP-01
                  TOTAL OIG ISSUED CONTRACT REPORTS  =  14
                                                                             1,210,764
                                                                                               24,010
                                                                                                               485,623 3,211,486
 HTTP.//WWW.EPA.GOV/OIGEARTH - PAGE 30

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 Report Number
                                   Title
                                                          Recommended
                	 Efficiencies
Final Report    Ineligible    Unsupported    Unreasonable (Funds Be Put
   Issued	Costs	Costs	Costs	To Better Use)
                                                                                       Questioned Costs
 2001-4-00010 Raven Ridge Resources Inc-FY99 Incurred Cost  03-APR-01
 2001-1-00125 Transcontinental  Enterprises,  Inc-FY98 Incurr 04-APR-01
              ed cost
 2001-1-00126 GRIFFIN  SERVICES-FY 1997 Incurred Cost        10-APR-01
 2001-4-00011 IT Group,  Inc-Indirect Bidding & Billing FYE  ll-APR-01
              2001-2003
 2001-4-00014 Battelle Memorial Inst-FY2001  Bidding & Bill! ll-APR-01
              ng Rates
 2001-1-00127 Battelle Memorial Inst-Follow-up Purchasing S ll-APR-01
              ys & 1C
 2001-4-00013 IT Group,  Inc-FY2001  Predetermined Daily Equi ll-APR-01
              pment Rates
 2001-4-00012 IT Group-FY2001 Direct Labor Estimating Rates ll-APR-01
 2001-1-00129 TRANSCONTINENTAL  ENTERPRISES-FY 1997  Incurred 12-APR-01
               Costs
 2001-4-00015 Foster Wheeler Envtl  Corp-Master File Vendor  12-APR-01
              IDs
 2001-4-00016 Foster Wheeler Envtl  Corp-Compensation 1C Fol 12-APR-01
              low-Up
 2001-4-00017 Foster Wheeler Envtl  Corp-Logical Security    12-APR-01
 2001-1-00131 ABB ENVIRONMENTAL - CAC 68-03-3452            12-APR-01
 2001-1-00130 MAR,  Inc-FY98 Incurred Cost                    12-APR-01
 2001-1-00132 INDUSTRIAL ECONOMICS  INC-FY  1998 Incurred Cos 19-APR-01
              t
 2001-1-00133 Foster Wheeler Environmental Corp-FY  1999 Inc 19-APR-01
              urred cost
 2001-1-00134 Environmental Management Support - CACS  68-W6 19-APR-01
              -0014
 2001-1-00135 Midwest  Research  Inst-MAAR 6                  16-MAY-01
 2001-1-00136 MIDWEST  RESEARCH  CORP-CACS 68-02-3817         16-MAY-01
 2001-1-00137 Midwest  Research  Inst-MAAR 13                  16-MAY-01
 2001-1-00138 FEV Engine Technology-Preaward PR-CI-01-11610 16-MAY-01
 2001-4-00019 FEV Engine Technology-Local  Travel Cost  Audit 17-MAY-01
 2001-4-00020 CET Environmental  Services Inc-Financial Revi 18-MAY-01
              ew/Revision
 2001-2-00020 Ricardo, Inc-Preaward PR-CI-01-11610           21-MAY-01
 2001-1-00139 Radian Corporation-CACS 68-W9-0072            22-MAY-01
 2001-1-00140 Metcalf  &  Eddy Inc-FY98 Incurred cost         22-MAY-01
 2001-1-00141 Foster Wheeler Environmental Corp-FY98  Incurr 23-MAY-01
              ed Cost
 2001-1-00142 SAIC-Review of Economy & Efficiency of Airfar 23-MAY-01
              e  Purchases
 2001-1-00144 Sierra Research Inc-FY99 Incurred cost         05-JUN-01
 2001-1-00147 Environmental Science  & Engineering-FY97  Incu 05-JUN-01
              rred  Cost
 2001-1-00145 Environmental Science  4 Engineering-FY98  Incu 05-JUN-01
              rred  Cost
 2001-1-00146 Kevric Company-FY99 Incurred cost              05-JUN-01
 2001-4-00021 Great  Lakes Environmental-FY 1999  Incurred  co 06-JUN-01
              st
 2001-1-00148  FY  2000  OMB Circular A-133 & Review of Indire 06-JUN-01
              ct  Rates
 2001-4-00022  Sierra Research Inc-FY98 Incurred  Cost         06-JUN-01
 2001-1-00149 Adeq/Comp  D/S Rev. 7c,8a,9a  eff.  01/99,1/00,1  ll-JUN-01
              /Ol
 2001-1-00150  SciComm  Inc-CACS 68-W3-0009                    ll-JUN-01
 2001-1-00151  Adeq./Comp. D/S Rev. 3c and  4a effective  l/l/  12-JUN-01
              99  and 1/1/2000
 2001-4-00023  Tetra  Tech Corp-Financial Capability  Review    12-JUN-01
 2001-1-00152  TAMS Consultant Inc-FY96 Incurred  cost         12-JUN-01
 2001-1-00153  DPRA-FY2001 Timkeeping  System-Floorcheck       12-JUN-01
 2001-1-00154  Foster Wheeler Environmental Corp-FY  1999 RAC  13-JUN-01
              68-W9-8214
 2001-1-00155  CFY 1999 Compliance w/  OMB Circular A-133      15-JUN-01
 2001-1-00158  Midwest Research Inst-FY2000 Incurred cost     26-JUN-01
 2001-1-00159  Computer Sciences  Corporation-CACS  68-01-7365  26-JUN-01
2001-1-00160  S COHEN & ASSOCIATES-FY 1998 Incurred Cost     27-JUN-01
2001-1-00161  EC/R Inc-FY97 Incurred Cost                    27-JUN-01
2001-2-00021 Review of Preward  RFP Number PR-R5-01-10719   27-JUN-01
2001-1-00162 Battelle Memorial  Inst-Follow-up Cost System  28-JUN-01
              & 1C
                78,223
                20,310
                       206,193
                                                                                   PAGE 31 -APRIL 1,2001 THROUGH SEPTEMBER 30,2001

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Report Number
                                  Title
                                                          Final Report
                                                             Issued
                                                                                      Questioned Costs
                                                                         Ineligible
                                                                          Costs
Unsupported
  Costs	
              Recommended
    	 Efficiencies
Unreasonable (Funds Be Put
  Costs	To Better Use)
              incurred
2001-1-00163 Battelle Memorial Inst-BMI-38 Revised Disclos 28-JUN-01
             ure Stmt
2001-1-00164 Washington Group Int'l, Inc-FY98 Direct cost  29-JUN-01

2001-1-00166 Stanford University-FY2000 Fringe Benefits    29-JUN-01
2001-1-00167 TetraTech/Black & Veatch JV-FYs 1997 & 1998 R 10-JUL-01
             AC
2001-1-00124 Westinghouse Remediation Svc-FY97 Incurred Co 16-JUL-01      13,190
             st
2001-1-00168 Coastal International Security-FY99 Incurred  17-JUL-01
             cost
2001-1-00169 Coastal International Security-FY98 Incurred  17-JUL-01
             Cost

2001-1-00171 Hazardous & Medical Waste Service-FY 1999 Inc 17-JUL-01
             urred cost
2001-1-00172 Environmental Management Support-FY2000 Incur 17-JUL-01
             red Cost
2001-1-00173 Technology Planning & Management Inc-FY98 Inc 18-JUL-01
             urred cost
2001-1-00174 Technology Planning & Management Corp-FY97 In 18-JUL-01
             curred Cost
2001-1-00175 Lockheed Martin Services-Budget System & Fina 18-JUL-01
             ncial Control
2001-1-00176 ManTech Environmental Technology-FY 1999 Incu 18-JUL-01
             rred cost
2001-1-00178 Syracuse Research Corporation-FY2000 Incurred 20-JUL-01
              cost
2001-4-00024 SciComm Inc-FY99 Incurred cost                13-AUG-01
2001-1-00179 Gannett Fleming Inc-Accounting System Audit   14-AUG-01
2001-1-00180 CAS Disclosure Statements effective Nov. I, 1 14-AUG-01
             997
2001-4-00025 I T Group FY2000 Financial Capability Risk As 14-AUG-01
             sessement
2001-1-00181 Gannett Fleming Environmental Engineers-FY99  15-AUG-01
             Incurred cost
2001-1-00183 Tetra Tech EMI-FY99 Incurred Cost             15-AUG-01
2001-1-00184 Computer Sciences Corporation-CACS 68-WO-0043 20-AUG-01
2001-2-00023 IT Group-Preaward DACW45-94-D-OOOS            20-AUG-01
2001-4-00026 Battelle Memorial Inst-Bidding & Billing 7/1/ 21-AUG-01
             01-9/30/01
             Lockheed Martin Service,  Inc-Follow-up Contro 21-AUG-01
             1 Envmt & Ace
             CET Environmental Services Inc-FY98 Incurred  24-AUG-01          479
             Cost
             Bechtel Group,  Inc-FY99  Incurred cost         24-AUG-Ol
             CET Inv. Review 68-W7-0016 D.O.#0016-060685  I 27-AUG-01
             nv.9685-004-05
             Eastern Research Group-EDP General Internal  C 07-SEP-01
             ontrols
             Milestone Associates,  Inc-Acc Sys & Financial 14-SEP-01
              Capability
       -00025 Proposal Review  RFP  PR-HQ-01-12880           17-SEP-01
       -00026 Review of Equipment Rates  68-W7-0016          17-SEP-01
       -00196 Lockheed Martin Services Group-FY 1999  Incurr 18-SEP-01
             ed  cost                                                         75,000
2001
2001
2001
2001
2001
2001
-1
-1
-1
-1
-1
-1
-00185
-00187
-00188
-00189
-00193
-00194
2001-2
2001-2
2001-1
                 TOTAL DCCA CONTRACT REPORTS =81
                                                                            393,395
 HTTP://WWW.EPA.GOV/OIGEARTH - PAGE 32

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Report Number
                                   Title
                                                           Final Report
                                                              Issued
                                                                                        Questioned Costs
Ineligible
 Costs
Unsupported
  Costs	
             Recommended
    	 Efficiencies
Unreasonable  (Funds Be Put
  Cogts	To Better Use)
2001-1-00165  2000  FIFRA  F/S AUDIT
                                                          29-JUN-01
                 TOTAL FINANCIAL STATEMENT REPORTS
2001-S-00012  Cash Management under Cooperative Agreements  26-SEP-01          0
2001-S-00008  Old Southington Landfill Response Claim       09-MAY-01          42,898
2001-S-00009 PREQB                                        27-JUN-01         0
2001-S-00010 PRP  Search  Program                          24-AUG-01         0
2001-S-00011 Penalty Collection                          21-SEP-01         0
                 0
                 1, 924
                 0
                 0
                 0
                            0
                            0
                            0
                            0
                            28,700,000
                 TOTAL SPECIAL REVIEW REPORTS  =  5

                 TOTAL REPORTS ISSUED = 239
 42,898

$3,036,989
   1,924

   $1,487,803
    0       28,700,000

    $485,623 $31,911,486
                                                                                     PAGE 33 - APRIL 1,2001 THROUGH SEPTEMBER 30,2001

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                       OIG MAILING ADDRESSES and TELEPHONE NUMBERS
                              OIG HOTLINE  1-888-546-8740 or (202) 260-4977
Headquarters
Environmental Protection Agency
Office of Inspector General
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Atlanta
Environmental Protection Agency
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Atlanta, GA 30303
Audit: (404) 562-9830
Investigations: (404) 562-9857

Boston
Environmental Protection Agency
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Suite HOO(Mailcode)
Boston, MA 02114-2023
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Chicago
Environmental Protection Agency
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13th Floor (IA-13 J)
Chicago, IL 60604
Audit: (312) 353-2486
Investigations: (312) 353-2507

Cincinnati
Environmental Protection Agency
Office of Inspector General
MS : Norwood
Cincinnati, OH 45268-7001
Audit: (513) 487-2360
Investigations: (312) 353-2507 (Chicago)

Dallas
Environmental Protection Agency
Office  of Inspector General (6OIG)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Audit: (214) 665-6621
Investigations: (404) 562-9857 (Atlanta)

Denver
Environmental Protection Agency
Office  of Inspector General
999 18th Street, Suite 500
Denver, CO 80202-2405
Audit:  (303) 312-6872
Investigations: (312) 353-2507 (Chicago)
           Kansas City
           Environmental Protection Agency
           Office of Inspector General
           901 N. 5th Street
           Kansas City, KS 66101
           Audit: (913) 551-7878
           Investigations: (312) 353-2507 (Chicago)

           New York
           Environmental Protection Agency
           Office of Inspector General
           290 Broadway, Room 1520
           New York, NY 10007
           Audit: (212) 637-3080
           Investigations: (212) 637-3041

           Philadelphia
           Environmental Protection Agency
           Office of Inspector General
           1650 Arch Street, 3rd Floor
           Philadelphia, PA  19103-2029
           Audit: (215) 814-5800
           Investigations: (215) 814-2361

           Research Triangle Park
           Environmental Protection Agency
           Office of Inspector General
           Catawba Building
           Highway 54, Mail Drop 53
           Research Triangle Park, NC 27711
           Audit: (919) 541-2204
           Investigations: (919) 541-1027

           Sacramento
           Environmental Protection Agency
           Office of Inspector General
           801 I Street, Room 264
           Sacramento, CA 95814
           Audit: (916) 498-6530
           Investigations: (415) 744-2465 (SF)

           San Francisco
           Environmental Protection Agency
           Office of Inspector General
           75 Hawthorne St. (IGA-1)
           7th Floor
           San Francisco, CA 94105
           Audit: (415)744-2445
           Investigations: (415) 744-2465

           Seattle
           Environmental Protection Agency
           Office of Inspector General
            1200 6th Avenue, 19th Floor
           Suite 1920, M/S OIG-195
           Seattle, WA 98101
           Audit: (206) 553-4033
           Investigations: (206) 553-1273
 HTTP://WWW.EPA.GOV/OIGEARTH- PAGE 34
U.S. Environmental Protection Agency
Region  5, Library (PL-12J)
77 West Jackson Boulevard, 12th Fta*
Chicago, IL   60604-3590

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